Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 28, 1992

MEMORANDUM FOR: R. DAVIS LAYNE
REGIONAL ADMINISTRATOR
THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Use of Cranes to Lift Personnel in Drilled Pier
Operations

This is in response to your memorandum requesting an interpretation of the requirements addressing the use of cranes to lower employees into drilled pier foundations. I apologize for the delay in responding to your inquiry.

We have recently addressed this issue in a letter to the International Association of Foundation Drilling. In that letter, we stated OSHA's position as follows: A boatswain chair suspended by reliable hoisting equipment utilizing an A-frame can be used by employees entering drilled pier foundations provided the applicable standards are met including the procedures outlined in 29 CFR 1926.451,1926.452(o) and 1926.651(g)(2)(ii). However, if jobsite conditions prevent the use of A-frame equipment or the use of such equipment would be more hazardous than the use of a crane, a mobile crane can be used for this purpose provided the employees are lowered in a personnel platform in accordance with the requirements of 29 CFR 1926.550(g).

We are aware that a standard personnel platform is often poorly designed to function well in a drilled pier application. However, we believe a platform could readily be designed that would comply with the requirements of 29 CFR 1926.550(g)(4) that would both provide protection for the employee entering the drilled pier and allow the necessary work to be performed.

In regard to whether there have been any variances granted by OSHA for similar activities, please be advised that we have no knowledge of any such variance being issued.